Mathis v. Pinnacle Entertainment Inc
5:11-cv-02199
W.D. La.Jun 23, 2014Background
- Mathis, a former Boomtown employee, missed work after a work-related back injury in April 2011, failed to complete accident and FMLA paperwork, and did not return to work.
- Boomtown sent letters warning that failure to contact by May 13 would be treated as voluntary resignation; Mathis later requested FMLA leave but did not return the required medical certification.
- Boomtown terminated Mathis on June 6, 2011 for violating the attendance policy.
- Mathis settled his workers’ compensation claim via a compromise agreement that broadly released claims “resulting from” his workplace accidents, while expressly reserving only EEOC and unemployment claims.
- Mathis sued pro se alleging FMLA interference/discrimination/retaliation and sought federal review of his state unemployment disqualification; Defendants moved for summary judgment.
- The district court granted summary judgment, holding the FMLA claims released by the compromise and, alternatively, failing on the merits; it also held no federal jurisdiction over the unemployment-review claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether FMLA claims were released by the workers’ compensation compromise agreement | Mathis: handwritten reservation of “unemployment claims” and discussion of FMLA before state agencies means FMLA claims were reserved | Defendants: agreement’s clear language releases all causes of action arising from the workplace accidents; reservation limited to EEOC and unemployment claims | Court: Agreement unambiguously released FMLA claims; reservation did not include FMLA; release enforced |
| Whether Mathis stated a prima facie FMLA discrimination/retaliation claim | Mathis: he requested FMLA leave, was terminated, and defendants’ failure to follow FMLA procedures shows retaliation/interference | Defendants: legitimate, nonretaliatory reason — prolonged absence and failure to submit required forms; no evidence of pretext | Court: Even assuming prima facie case, Mathis offered no evidence of pretext; claims fail on the merits |
| Whether defendants interfered with Mathis’s attempt to take FMLA leave | Mathis: alleged employees obstructed his leave attempts (asserted but provided no proof) | Defendants: no evidence of interference; requested forms were sent and not returned | Court: No evidence of interference; claim dismissed |
| Whether federal court has jurisdiction to review state unemployment decision | Mathis: federal court appropriate because FMLA (a federal law) implicated in unemployment determination | Defendants: unemployment-review is a state-law matter; any federal issue is not substantial for federal jurisdiction | Court: No federal-question jurisdiction under well-pleaded complaint or Grable factors; claim must be adjudicated in state forum |
Key Cases Cited
- Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden and standard)
- Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (standard for genuine issue of material fact)
- EEOC v. Chevron Phillips Chem. Co., 570 F.3d 606 (Fifth Circuit standard on summary judgment and evidence view)
- Bocalbos v. Nat'l W. Life Ins. Co., 162 F.3d 379 (FMLA substantive framework)
- Ruhrgas AG v. Marathon Oil Co., 526 U.S. 574 (court's duty to police subject-matter jurisdiction)
- Beneficial Nat'l Bank v. Anderson, 539 U.S. 1 (well-pleaded complaint rule for federal-question jurisdiction)
- Grable & Sons Metal Prods., Inc. v. Darue Eng'g & Mfg., 545 U.S. 308 (Grable test for federal jurisdiction over state-law claims presenting federal issues)